Monthly Archives: January 2013

Bad Sanctions: Who’s to Blame?

I was recently re-reading the Judicial Review Commission Report on Foreign Assets Control (“Report”), a 2000 report on the implementation of the Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). A few key points from that Report got me thinking about the overall state of U.S. economic sanctions and where some of the more onerous provisions...
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Setting the Record Straight on Hagel, Iran Sanctions

Since the announcement that President Barack Obama would nominate former Nebraska Sen. Chuck Hagel as Secretary of Defense, many have pointed to his past opposition to some Iran sanctions legislation as evidence that, in the words of Sen. John Cornyn (R-Texas), he “does not fully appreciate the dangers of a nuclear Iran or the character...
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New Sanctions on Iran and Neo-Big Stick Diplomacy

Contained in the Defense Authorization Act (NDAA) of 2013, and signed into law by President Obama on January 2, are sweeping new sanctions targeting Iran over its disputed nuclear program. The new measures target foreign entities engaging in a wide array of transactions with Iran, including the sale of any goods supporting Iran’s energy, shipping...
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OFAC Starts Off 2013 With An Enforcement Action

On the first business day of the new year, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $191,700 settlement of sanctions violations with Ellman International, Inc. (“Ellman”) for apparent violations of the Iranian Transactions Regulations (“ITR”). Under it’s prior ownership and management Ellman exported products to Iran and...
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